1. Moderator John C. Bourbon Chairman United kingdom Compliance Institute Risk Management and Internal Controls - KYC for Banks

2. Risk Based Approach to AML/CFT Detailed Procedures Role of Money Laundering Reporting Officer Use of Technology driven solutions

3. What should a firm’s KYC Framework look like? Guarding the door for new business Monitoring of existing clients Monitoring existing staff performance Robust recruitment Processes

4. What sort of Customer Due Diligence procedures should be established? Establish the full identity Obtain copies of Passport / Identity papers Check and verify full personal addresses Establish anticipated activity and model accordingly

5. What are the key controls ? Customer profiling Transaction profiling Sanctions screening Document retention

6. How should the key controls be monitored? Defaults incorporated in reporting systems Reports produced for Compliance & MLRO Random visits by Compliance Officer and MLRO Internal Audit External Auditor

7. What are the key risk indicators? Unusual and unexplained transactions Large volumes with little economic logic Small transactions in bulking up into much larger single transactions Transactions spread across a large number of outlets

8. What sort of training regime should be put in place? All staff trained at least annually All staff tested annually Regular updates on latest trends and ideas

9. John C Bourbon MSc FCIB FCSI FCol John Bourbon is licensed by the Isle of Man Financial Supervision Commission as a Trust and Corporate Services Provider Contacts: www.complianceinstitute.co.uk www.johnbourbonconsulting.com E-mail johncb@manx.net +44 7624 233603 / +44 7624 433603